Paragraph 8
United Kingdom
In section 690D (employer notification for qualifying new residents)—
for the words from “the proportion” to the end substitute
“—
(i)the best estimate that can reasonably be made of the overall proportion of the amount of all qualifying payments made by the employer to the employee that is likely to be qualifying foreign employment income,”;
at the end of that sub-paragraph insert
“or
(ii)if the best estimate mentioned in sub-paragraph (i) is greater than 30%, 30%.”;
in subsection (6), after paragraph (a) insert—
“(aa)as a result of a change in the employee’s circumstances, the proportion specified in the notice ceases to be a reasonable estimate of the overall proportion of the amount (as applicable) of—
(i)all qualifying payments that is likely to be qualifying foreign employment income, or
(ii)all treaty affected payments in respect of which UK tax is likely to be relieved under double taxation arrangements,”.
The amendment made by sub-paragraph (1)(a)(ii) does not apply to a notification relating to an employee and tax year 2026-27 or 2027-28 if section 41R of ITEPA 2003 (limit on relief) would not apply to a foreign employment relief claim made by the employee for that year, if that year was the qualifying year (see paragraph 7 of Schedule 8 to FA 2025 (limit on relief not to apply to certain foreign employment relief claims)).